PC PPP Holsinger Presents: Life after - Confidential 2020 Holsinger P.C. All Rights Reserved.
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Holsinger
PC
Presents:
Life after
PPP
Confidential ©2020 Holsinger P.C. All Rights Reserved.
Agenda
Update on Economic Impact Payments (Stimulus Checks)
Updates on Federal and State Due Dates
States’ Reaction to the CARES Act
Additional guidance provided on the PPP Loans including:
Loan forgiveness
Self Employed Individuals
Updates on the Payroll Credit Programs
Main Street Lending Program
Confidential ©2020 Holsinger P.C. All Rights Reserved.
Update on the Economic Impact
Payment (Stimulus Checks)
The initial round of more than 80 million Economic Impact Payments started to hit bank accounts last weekend
and throughout this week according to IR-2020-72 issued April 15, 2020 by the IRS.
https://www.irs.gov/newsroom/economic-impact-payments-what-you-need-to-know
The maximum credit is:
◦ $1,200 for each eligible individual (so $2,400 for two eligible individuals who file a joint return) plus
◦ $500 for each qualifying child (Code Section 6428(a), as added by the CARES Act)
◦ A qualifying child is generally:
◦ A taxpayer’s son, daughter, stepchild, adopted child, foster child, brother, sister, stepbrother, stepsister or a descendent of any of them
who was under age 17 at the end of the tax year, lived with the taxpayer for more than half of year
◦ Did not provide over half of his or her own support for the year
◦ Was a US Citizen, US National, Or Us Resident
◦ Is claimed as a dependent on the taxpayer’s tax return and
◦ Has a SSN (or other identification number) that is reported on the tax return
Also on April 15, 2020 the IRS, working in partnership with the Treasury Department and the Social Security Administration, a nnounced that
recipients of Supplemental Security Income (SSI) will automatically receive automatic Economic Impact Payments of $1,200 each.
No further action needed on the part of the recipient and those payments projected to go out no later than early May
Confidential ©2020 Holsinger P.C. All Rights Reserved.
Helpful IRS Websites
Get My Payment Non-Filers: Enter Payment Info Here
On April 15, the Get My Payment tool was launched on the IRS website Who should use Non-Filers: Enter Payment Info to provide
which will assist with the following: additional information to receive the Economic Impact
Payment?
Show the projected date when a deposit has been scheduled
(similar to the “Where’s My Refund tool”) Eligible U.S. citizens or permanent residents who:
Allows people to provide their bank account information
For those that did not use direct deposit on their last tax return
Had gross income that did not exceed $12,200 ($24,400 for
married couples) for 2019
will be able to input their information
Please have your latest tax return filed handy as it will ask for AGI Were not otherwise required to file a federal income tax
and tax owed/refund requested (2019 or 2018 return) return for 2019, and didn't plan to
The site is updated once daily, usually overnight. The IRS urges You can provide the necessary information to the IRS easily
taxpayers to only use Get My Payment once a day and quickly for no fee through Non-Filers: Enter Payment
Info. We will use this information to determine your
If information you enter does not match the IRS records multiple times, you eligibility and payment amount and send you an Economic
will be locked out of Get My Payment for 24 hours for security reasons. Impact Payment. After providing this information you
won’t need to take any additional action.
Unfortunately, there is no way to contact the IRS with any technical issues
with the site. https://www.irs.gov/coronavirus/non-filers-enter-
payment-info-here
https://www.irs.gov/coronavirus/get-my-payment
Confidential ©2020 Holsinger P.C. All Rights Reserved.
Helpful IRS Websites
Coronavirus Tax Relief and Economic Impact Economic Impact Payment Information Center:
Payments:
https://www.irs.gov/coronavirus/economic-
https://www.irs.gov/coronavirus-tax-relief- impact-payment-information-center#bank
and-economic-impact-payments
On this page...
Allows you to check your payment status ◦ Eligibility and General Information
Provides latest updated on Coronavirus Tax ◦ Accessing Get My Payment
Relief ◦ Payment Status
◦ Payment Status Not Available
Provides information for
◦ Bank Account Information
◦ Individuals and families
◦ Locked/Status Unavailable
◦ Businesses and Tax-Exempt Entities
◦ Error Message
◦ Health Plans and Retirement Plans
◦ Address Changes
Confidential ©2020 Holsinger P.C. All Rights Reserved.
Source: https://www.irs.gov/newsroom/irs-statement-on-get-my-payment-application-status-not-
available
April 15, 2020
The Get My Payment site is operating smoothly and effectively. As of mid -day today, more than 6.2
million taxpayers have successfully received their payment status and almost 1.1 million taxpayers
have successfully provided banking information, ensuring a direct deposit will be quickly sent. IRS is
IRS Statement actively monitoring site volume; if site volume gets too high, users are sent to an online “waiting
room” for a brief wait until space becomes available, much like private sector online sites. Media
reports saying the tool “crashed” are inaccurate.
on Get My In situations where payment status is not available, the app will respond with “Status Not
Payment Available”. The IRS reminds users you may receive this message for one of the following reasons:
If you are not eligible for a payment (see IRS.gov on who is eligible and who is not eligible)
Application: If you are required to file a tax return and have not filed in tax year 2018 or 2019.
Status Not If you recently filed your return or provided information through Non -Filers: Enter Your Payment Info
on IRS.gov. Your payment status will be updated when processing is completed.
Available If you are a SSA or RRB Form 1099 recipient, SSI or VA benefit recipient – the IRS is working with your
agency to issue your payment; your information is not available in this app yet.
You can check the app again to see whether there has been an update to your information. The IRS
reminds taxpayers that Get My Payment data is updated once per day, so there’s no need to check
back more frequently.
The IRS continues to closely monitor the situation. In addition, more information will be shared on
IRS.gov shortly on some common questions taxpayers are asking.
Confidential ©2020 Holsinger P.C. All Rights Reserved.
Due Dates
Notice 2020-18
◦ The due date for filing Federal income tax returns and making Federal income tax
payments due April 15, 2020 is automatically postponed to July 15, 2020 for
individuals, a trust, estate, partnership, association, company or corporation
Notice 2020-20
◦ Extended the due date for filing Forms 709 (US Gift Tax Return) and making
payments of Federal gift tax due April 15, 2020 to July 15, 2020
Notice 2020-23
◦ The Secretary of the Treasury has determined that any person with a Federal tax
payment obligation specified in the notice or a Federal tax return or other form filing
obligation specified in in the notice, which is due to be performed (originally or
pursuant to a valid extension) on or after April 1, 2020, and before July 15, 2020, is
affected by the COVID-19 emergency for purposes of the relief described in the
notice.
◦ Among other things, effectively extended all second quarter estimated tax payments
to July 15, 2020
Confidential ©2020 Holsinger P.C. All Rights Reserved.IRS Filing and Payment Deadlines
Questions and Answers
The IRS has a website related to questions and answers on Notice 2020-18 regarding Federal
income tax return filing and payment relief.
https://www.irs.gov/newsroom/filing-and-payment-deadlines-questions-and-answers
Topics include:
Eligibility
Filing and paying your 2019 Federal income taxes and your first quarter 2020 Federal estimated
income taxes
Individual Retirement Accounts (IRAs) and workplace-based retirement plans
Health Savings Accounts (HSAs) and Archer Medical Savings Accounts (MSAs)
Other Questions
Confidential ©2020 Holsinger P.C. All Rights Reserved.Pennsylvania filing and payment deadline has been
extended to July 15, 2020 for all personal income
tax returns which includes 1st and 2nd Quarter
Estimates.
Pennsylvania corporate taxpayers who had annual
corporate net income tax returns and payments due
Pennsylvania in April, May, June or July of 2020 now have until
August 14, 2020 to file their returns and make their
final payments.
Visit PA Dept. of Revenue Website for Additional
information on COVID-19
https://www.revenue.pa.gov/Pages/COVID19.aspx
Confidential ©2020 Holsinger P.C. All Rights Reserved.https://www.revenue.pa.gov/Pages/COVID19.aspx
Pennsylvania Due Dates
Confidential ©2020 Holsinger P.C. All Rights Reserved.What about the other states?
Per the AICPA State Tax Filing Guidance updated on 4/15/2020:
All states with a personal income tax have extended their 4/15 due dates
◦ 40 states (including DC) individual income tax and some other entities 4/15 to 7/15 filing and payments
deadline for coronavirus pandemic. [AK, AL, AR, AZ, CA, CO, CT, DC, DE, GA, IL, IN, KS, KY, LA, MA, ME, MD, MI,
MN, MO, MT, NC, ND, NE, NJ, NM, NY, OH, OK, OR, PA, RI, SC, TN, TX, UT, VT, WI, WV]
◦ 5 states for individual income tax changed to other filing and payments deadline for coronavirus pandemic [IA
(7/31), HI, (7/20), ID (6/15), MS (5/15), VA (filings 5/1, 6/1 payments)] and Puerto Rico (6/15).
◦ 2 states for other taxes have changed deadlines for the pandemic [NH (6/15 - business tax, interest and
dividends tax, WA (6/15 - annual business and occupation tax)]
◦ 4 states providing a temporary safe harbor or waiver for state withholdings and tax liability for remote work in
different state during pandemic [DC, MS, NJ, and PA]
We advise you to go to the state Dept. of Revenue website to verify all filing deadlines and payment due dates.
Here is a website that will direct you to any state’s taxing authority website:
https://www.taxadmin.org/state-tax-agencies
Confidential ©2020 Holsinger P.C. All Rights Reserved.CARES Act – what about the states?
As we’ve learned from prior laws enacted, states generally fall into three categories or methods of conformity to
the IRC:
1. Rolling – conforms to the IRC automatically or “as amended” and the state legislature must specifically
decouple from amendments to the IRS, otherwise the state conforms to any federal changes (examples are IL,
MA, NJ, NY, TN)
2. Fixed-date – state conforms to the IRC as of a date certain (AZ, FL, GA, MI, TX)
3. Selective – state conforms only to specific IRS sections on a rolling basis or on a fixed date basis (PA, CA)
It is reasonable to expect certain states to decouple from some or all of the CARES Act provisions.
On April 3, 2020, New York (a rolling conformity state) became the first state to decouple from certain features of
the CARES act for corporation franchise tax and personal income tax purposes.
For corp. franchise tax purposes, for taxable years beginning in 2019 and 2020, the increase in the 163(j) limitation from 30%
to 50% will not be followed by NYS
For state and city personal income tax purposes, any amendments to the IRC made after March 1, 2020 will not apply
Confidential ©2020 Holsinger P.C. All Rights Reserved.And what about the
PPP loan forgiveness?
States generally follow federal treatment of debt
discharge so we would expect states to incorporate the
PPP loan forgiveness as well – but only if the state
conforms to the most recent version of the IRC which
includes the exception.
States with Static Conformity will need to update their
conformity in order to include the exception provided in
the CARES Act
As Jared Walczak points out in his article titled “Will
States Tax the Federal Government’s COVID-19 Lifeline to
Small Businesses” dated April 13, 2020, “if states fail to
update their conformity date to a date after the
implementation of the CARES Act or otherwise make
express provision for its exclusion from the tax base, they
will wind up taxing this federal lifeline to small
businesses.”
https://taxfoundation.org/small-business-loan-forgiveness-sba-ppp-loan-taxed/
Confidential ©2020 Holsinger P.C. All Rights Reserved.Loan Forgiveness:
What we Knew:
On March 27, 2020, the CARES Act (the “Act”) established the Paycheck Protection Program
(“PPP”) (Section 1102 of the Act)
The Act established guidelines for the determination of loan availability to “small” businesses,
sole proprietors, independent contractors and eligible self-employed individuals.
Banks were tasked with creating internal platforms to facilitate applications
◦ Business applicants were to be able to apply by 4/3/2020
◦ Sole Proprietors, Independent Contractors and Eligible Self-employed Individuals were to be able to
apply on 4/10/2020.
Confidential ©2020 Holsinger P.C. All Rights Reserved.Loan Forgiveness:
Reality:
Some banks began accepting application on 4/3/2020 with little or no guidance regarding what
to do with them from the SBA.
◦ These banks struggled to maintain an organized application process given the volume of applications
received and the inability of the platforms to handle the internet traffic.
◦ These banks largely oversimplified the application process asking as the outset only for the application
itself and not the corroborating application evidence.
◦ These banks largely held application received internally in anticipation of further guidance from the
SBA.
◦ While the effort was appreciated, it did not necessarily advance applicants from an SBA processing
perspective.
◦ Rather, it could have delayed processing as a result of requiring preparation and upload of supporting
information after the initial application was completed.
Confidential ©2020 Holsinger P.C. All Rights Reserved.Loan Forgiveness:
Reality:
Banks feared liability resulting from misrepresentation of application information:
◦ In order to mitigate risk, most banks only took applications from existing customers and bank
relationships.
◦ Applicants without an exiting relationship were required to reference the SBA “Find A Lender Service”
which was frequently down as the link could not support the internet traffic.
Most banks came online 4/6/2020 (a few came online over the weekend).
All banks had unique application processes:
◦ Most requested similar information, but each bank seemed to have its own version of all the forms.
◦ Dates and calculation methodologies varied
◦ Calendar vs. TTM average monthly payroll cost determination
◦ Inclusion/exclusion of 1099 costs
Confidential ©2020 Holsinger P.C. All Rights Reserved.Loan Forgiveness:
Reality:
All applicants likely went through a series of requests and submittals
Only this week did companies begin to receive the funding
Sole Proprietors, Independent Contractors and Eligible Self-employed Individuals were able to apply
on 4/10/2020, however:
◦ No formal instruction was provided until 4/14
◦ Banks did not actually process these requests until that guidance was issued (only beginning to process now).
Where is the Money?
◦ As of 4/16/2020 all of the $349B allotted to the PPP is spoken for.
◦ Banks are unsure as to whether or not the entirety of the funding is “committed” or disbursed?
◦ If “committed”… Where is the line drawn for existing applicants?
◦ Another round of stimulus funding is in the works ($250B)
◦ $350B was spoken for in a weeks’ time… How long will an additional $250B last… Days?
◦ Will there be more when the next round runs out.
◦ How deep can this hole get?
Confidential ©2020 Holsinger P.C. All Rights Reserved.Loan Forgiveness:
Reality
Aside from the receipt of funds
Loan forgiveness is now at the forefront of applicant concerns
(other than receiving the funding itself)
◦ We were hopeful to see Loan Forgiveness Standard Operating
Procedure by now (we have not)
◦ The best sources of information regarding loan forgiveness are
the Act itself, the Interim Final Rule/Initial Rule, and SBA FAQ.
But first, let’s look at the tax implications of the
loan forgiveness…
Confidential ©2020 Holsinger P.C. All Rights Reserved.Loan Forgiveness:
Reality:
Is Free Really Free?
◦ Section 1106 of the CARES Act states that amounts forgiven on a PPP loan “shall be excluded from gross income.”
However, Section 265 of the Internal Revenue Code provides that expenses “allocable to” tax-exempt income are not
deductible; this prevents a “double dipping” of sorts, whereby a taxpayer would otherwise get both a deduction and
tax-exempt income related to the same transaction or investment.
◦ Historically, Section 265 has applied to items like interest expense incurred to generate tax-exempt interest income,
but we believe it could apply to expenses paid with forgiven PPP proceeds.
◦ In Manocchio v. Commissioner, an airline pilot paid for flight instruction and was ultimately 90% reimbursed under
a federal program. The reimbursed payments were tax-exempt, leading the IRS to apply Section 265 and disallow
any deduction related to the payment for the program.
◦ We can assume the IRS will take the same approach to forgiven PPP loans.
◦ As Tony Nitti points out in the Forbes Article “Ten Things We need to Know About Paycheck Protection Program
Loan Forgiveness” on April 15, 2020, “claiming deductions for amounts paid for by the federal government on a
tax-free basis – and potentially generating a loss that can now be carried back to collect a refund of previously paid
taxes – would be an extremely generous outcome.”
https://www.forbes.com/sites/anthonynitti/2020/04/15/ten-things-we-need-to-know-about-paycheck-protection-program-loan-forgiveness/#4ba61fed3291
Let’s take a closer look at this…
Confidential ©2020 Holsinger P.C. All Rights Reserved.Loan Forgiveness –
What does it look like in reality?
LIFE BEFORE PPP LOAN LIFE AFTER PPP LOAN
No PPP With PPP Tax Exempt
Gross Income 1,000,000.00 Gross Income 1,000,000.00
PPP Loan Forgiveness 52,083.33
Payroll (250,000.00)
Rent/Utilities (25,000.00) Payroll (210,000.00) (40,00.00)
Rent/Utilities (12,916.67) (12,083.33)
Other Expenses (125,000.00)
Other Expenses (125,000.00)
Taxable Income 600,000.00
Taxable Income 652,083.33 0.00
Highest Tax Bracket for Individual 0.37
Highest Tax Bracket for Individual 0.37
Tax 222,000.00
Tax 241,270.83
Cash Output Cash Output
Net Income 600,000.00 Net Income 600,000.00
Loans Received 0.00 Loans Received 52,083.33
Taxes Paid (222,000.00) Taxes Paid (241,270.83)
Net Cash Outlay at Year End 378,000.00 Net Cash Outlay at Year End 410,812.50
Loan 52,083.33
Net Tax Increase (19,270.83)
Actual Loan Forgiveness 32,812.50
Confidential ©2020 Holsinger P.C. All Rights Reserved.Loan Forgiveness -
What The Act Says:
Section 1106: An eligible recipient shall be eligible for forgiveness of indebtedness on a covered
loan in an amount equal to the sum of the following costs incurred and payments made during
the covered period:
◦ Payroll costs.
◦ Any payment of interest on any covered mortgage obligation (which shall not include any prepayment
of or payment of principal on a covered mortgage obligation).
◦ Any payment on any covered rent obligation.
◦ Any covered utility payment.
Confidential ©2020 Holsinger P.C. All Rights Reserved.What The Act Says:
Section 1106: An eligible recipient shall be eligible for forgiveness of indebtedness on a covered loan
in an amount equal to the sum of the following costs incurred and payments made during the
covered period:
◦ Definitions:
◦ Covered Period: the 8-week period beginning on the date of the origination of a covered loan.
◦ We interpret this to me the 8-wek period following the receipt of PPP proceeds.
◦ Payroll Costs: Same as the definition under section 1102: Paraphrased:
◦ Includes: Payment of salaries, wages, bonuses commissions and other similar compensation (capped at $100K per employee);
Payment of employer share of state and local tax (SUTA); Payment of retirement contributions; Payment of health insurance
premiums.
◦ Does not include: Employee gross wages in excess of $100K ($8,333/month); Compensation of employees with residences
outside the U.S.; Employee Federal Withholdings (during the Covered Period); Other wages/taxes that conflict with other
provisions of the Act.
◦ NOTE THAT IN THIS SECTION (1102), COVERED PERIOD IS DEFINED AS THE PERIOD BEGINNING 2/15/20 AND ENDING 6/30/20.
◦ INTENTIONAL OR UNINTENTIONAL: THE WAY THE ACT IS WRITTEN, ONLY NET WAGES, PLUS EMPLOYEE STATE AND LOCAL
WITHHOLDINGS, PLUS EMPLOYER SHARE OF STATE AND LOCAL TAX (SUTA), WILL COUNT FOR PURPOSES OF DETERMINING
LOAN FORGIVENESS…
◦ LIKELY TO CREATE SPENDING ISSUES…
◦ WILL THIS GET CLARIFIED AGAIN? STAY TUNED…
Confidential ©2020 Holsinger P.C. All Rights Reserved.What The Act Says:
Section 1106: An eligible recipient shall be eligible for forgiveness of indebtedness on a covered
loan in an amount equal to the sum of the following costs incurred and payments made during
the covered period:
◦ Covered Mortgage Obligation: Not Defined
◦ NOTE THAT INTEREST ON OTHER INDEBTEDNESS IS NOT INCLUDED.
◦ Note: The interim final rule on SE applicants defines this to include mortgages on real and personal property and gives an
example of a company vehicle. Is this specific to SE applicants or can business applicants use the same definition?
◦ Covered Rent Obligation: Rent obligated under a leasing agreement before February 15, 2020.
◦ Note: The SE interim final rule includes rent on personal property. Is this specific to SE applicants or can business applicants use
the same definition?
◦ Covered Utility Payment: payment for a service for the distribution of electricity, gas, water, transportation, telephone, or internet
access for which service began before February 15, 2020.
Confidential ©2020 Holsinger P.C. All Rights Reserved.What The Act Says:
Limits on the amounts of Loan Forgiveness
◦ AMOUNT MAY NOT EXCEED PRINCIPAL: The amount of loan forgiveness under this section shall not
exceed the principal amount of the financing made available under the applicable covered loan.
◦ LATER CLARIFIED BY THE SBA. IT IS SPECIFICALLY NOTED THAT INTEREST WILL ACCRUE AT 1% FROM THE DATE OF RECEIPT OF
PROCEEDS, HOWEVER, ACCRUED INTEREST WILL BE FORGIVABLE AS WELL AS PRINCIPAL.
◦ REDUCTION BASED ON REDUCTION IN NUMBER OF EMPLOYEES:
◦ IN GENERAL.—The amount of loan forgiveness under this section shall be reduced, but not increased, by multiplying the amount
described in subsection (b) by the quotient obtained by dividing: (i) the average number of full-time equivalent employees per
month employed by the eligible recipient during the covered period; by, at the election of the borrower, (1) the average number of
full time equivalent employees per month employed by the eligible recipient during the period beginning on February 15, 2019
and ending on June 30, 2019; or; the average number of full time equivalent employees per month employed by the eligible
recipient during the period beginning on January 1, 2020 and ending on February 29, 2020; or; in the case of an eligible recipient
that is seasonal employer, as determined by the Administrator, the average number of full-time equivalent employees per month
employed by the eligible recipient during the period beginning on February 15, 2019 and ending on June 30, 2019.
◦ CALCULATION OF AVERAGE NUMBER OF EMPLOYEES: The average number of full-time equivalent employees shall be determined
by calculating the average number of full-time equivalent employees for each pay period falling within a month.
Confidential ©2020 Holsinger P.C. All Rights Reserved.What The Act Says:
◦ REDUCTION RELATING TO SALARY AND WAGES:
◦ IN GENERAL: The amount of loan forgiveness under this section shall be reduced by the amount of any reduction in total salary or wages of
any employee during the covered period that is in excess of 25 percent of the total salary or wages of the employee during the most recent
full quarter during which the employee was employed before the covered period.
◦ EMPLOYEES DESCRIBED: An employee described in this provision is any employee who did not receive, during any single pay period during
2019, wages or salary at an annualized rate of pay in an amount more than $100,000.
◦ EXEMPTION FOR RE-HIRES:
◦ IN GENERAL: In a circumstance described below, the amount of loan forgiveness under this section shall be determined without regard to a
reduction in the number of full-time equivalent employees of an eligible recipient or a reduction in the salary of 1 or more employees of the
eligible recipient, as applicable, during the period beginning on February 15, 2020 and ending on the date that is 30 days after the date of
enactment of this Act (April 27, 2020).
◦ A circumstance in which:
◦ During the period beginning on February 15, 2020 and ending on the date that is 30 days after the date of enactment of this Act (April 27,
2020), there is a reduction, as compared to February 15, 2020, in the number of full-time equivalent employees of an eligible recipient;
and, not later than June 30, 2020, the eligible employer has eliminated the reduction in the number of full-time equivalent employees;
◦ A circumstance in which:
◦ During the period beginning on February 15, 2020 and ending on the date that is 30 days after the date of enactment of this Act
(4/27/2020), there is a reduction, as compared to February 15, 2020, in the salary or wages of 1 or more employees of the eligible
recipient; and not later than June 30, 2020, the eligible employer has eliminated the reduction in the salary or wages of such employees.
Confidential ©2020 Holsinger P.C. All Rights Reserved.The Interim Final Rule Says (4/3/2020
Version):
Section 1106 of the Act provides for forgiveness of up to the full principal amount of qualifying loans
guaranteed under the Paycheck Protection Program. On April 2, 2020, SBA issued an interim final
rule (the Initial Rule) announcing the implementation of sections 1102 and 1106 of the Act. A more
detailed discussion of sections 1102 and 1106 of the Act is found in section III of the Initial Rule. This
interim final rule supplements the Initial Rule with additional guidance regarding the application of
certain affiliate rules applicable to SBA’s implementation of sections 1102 and 1106 of the Act and
requests public comment.
The Initial Interim Final Rule (4/2/2020 Version) says:
◦ This interim final rule outlines the key provisions of SBA’s implementation of sections 1102 and 1106 of
the Act in formal guidance and requests public comment.
◦ All of the provisions of forgiveness are the same except, certain elements are clarified:
◦ Is there anything that is expressly excluded from the definition of payroll costs?
◦ Federal employment taxes imposed or withheld between February 15, 2020 and June 30, 2020, including the employee’s and
employer’s share of FICA (Federal Insurance Contributions Act) and Railroad Retirement Act taxes, and income taxes required to
be withheld from employees.
◦ SOUNDS LIKE NET PAY, PLUS STATE AND LOCAL TAX W/H, PLUS EMPLOYER SHARE OF STATE AND LOCAL (SUTA).
Confidential ©2020 Holsinger P.C. All Rights Reserved.The Interim Final Rule Says (4/3/2020
Version):
◦ All of the provisions of forgiveness are the same except, certain elements are clarified:
◦ Can my PPP loan be forgiven in whole or in part?
◦ Yes. The amount of loan forgiveness can be up to the full principal amount of the loan and any accrued interest. That is, the
borrower will not be responsible for any loan payment if the borrower uses all of the loan proceeds for forgivable purposes
described below and employee and compensation levels are maintained. The actual amount of loan forgiveness will depend, in
part, on the total amount of payroll costs, payments of interest on mortgage obligations incurred before February 15, 2020, rent
payments on leases dated before February 15, 2020, and utility payments under service agreements dated before February 15,
2020, over the eight-week period following the date of the loan. However, not more than 25 percent of the loan forgiveness
amount may be attributable to nonpayroll costs. While the Act provides that borrowers are eligible for forgiveness in an amount
equal to the sum of payroll costs and any payments of mortgage interest, rent, and utilities, the Administrator has determined
that the non-payroll portion of the forgivable loan amount should be limited to effectuate the core purpose of the statute and
ensure finite program resources are devoted primarily to payroll. The Administrator has determined in consultation with the
Secretary that 75 percent is an appropriate percentage in light of the Act’s overarching focus on keeping workers paid and
employed. Further, the Administrator and the Secretary believe that applying this threshold to loan forgiveness is consistent with
the structure of the Act, which provides a loan amount 75 percent of which is equivalent to eight weeks of payroll (8 weeks / 2.5
months = 56 days / 76 days = 74 percent rounded up to 75 percent). Limiting non-payroll costs to 25 percent of the forgiveness
amount will align these elements of the program and will also help to ensure that the finite appropriations available for PPP loan
forgiveness are directed toward payroll protection. SBA will issue additional guidance on loan forgiveness.
Confidential ©2020 Holsinger P.C. All Rights Reserved.The Interim Final Rule Says (4/3/2020
Version):
◦ All of the provisions of forgiveness are the same except, certain elements are clarified:
◦ Can my PPP loan be forgiven in whole or in part?
◦ This adds the 75% usage on payroll cost provision. i.e. 75% of PPP Proceeds spent need to be on “Payroll Costs”.
◦ HOW WILL THIS BE MEASURED?
◦ IS THIS AN ALL OR NOTHING PROVISION OR IS THIS A PROPORTIONAL REDUCTION OF FORGIVENESS IF BELOW 75%?
◦ Note the mention of not only a requirement to maintain employee levels (employee number) but employee compensation
(dollars paid) as well.
◦ WILL THIS BE FURTHER CLARIFIED?
◦ How can PPP loans be used?
◦ The proceeds of a PPP loan are to be used for: 1) payroll costs (as defined in the Act and in 2.f. of the Initial Rule – Interim Final
Rule); 2) costs related to the continuation of group health care benefits during periods of paid sick, medical, or family leave, and
insurance premiums; 3) mortgage interest payments (but not mortgage prepayments or principal payments); 4) rent payments;
5) utility payments; 6) interest payments on any other debt obligations that were incurred before February 15, 2020; and/or 7)
refinancing an SBA EIDL loan made between January 31, 2020 and April 3, 2020. If you received an SBA EIDL loan from January
31, 2020 16 through April 3, 2020, you can apply for a PPP loan. If your EIDL loan was not used for payroll costs, it does not affect
your eligibility for a PPP loan. If your EIDL loan was used for payroll costs, your PPP loan must be used to refinance your EIDL
loan. Proceeds from any advance up to $10,000 on the EIDL loan will be deducted from the loan forgiveness amount on the PPP
loan.
◦ NOTE THE MENTION OF INTEREST ON PREEXISTING OTHER DEBT FACILITIES? DOES THIS QUALIFY FOR FORGIVENESS?
◦ INCONSISTENT TREATMENT THUS FAR.
Confidential ©2020 Holsinger P.C. All Rights Reserved.The SBA FAQ Says:
Q7: The CARES Act excludes from the definition of payroll costs any employee compensation in
excess of an annual salary of $100,000. Does that exclusion apply to all employee benefits of
monetary value?
◦ No. The exclusion of compensation in excess of $100,000 annually applies only to cash compensation,
not to non-cash benefits, including:
◦ employer contributions to defined-benefit or defined-contribution retirement plans;
◦ payment for the provision of employee benefits consisting of group health care coverage, including insurance premiums; and
◦ payment of state and local taxes assessed on compensation of employees.
◦ NOTE THE EXCLUSION OF STATE AND LOCAL TAXES ASSESSED ON COMPENSATION OF EMPLOYEES?
CONTRADICTS THE GROSS WAGE CONCEPT ABOVE IF THAT INCLUDES EMPLOYEE STATE AND
LOCAL TAX WITHHOLDINGS…
Confidential ©2020 Holsinger P.C. All Rights Reserved.The SBA FAQ Says:
Q16: How should a borrower account for federal taxes when determining its payroll costs for
purposes of the maximum loan amount, allowable uses of a PPP loan, and the amount of a loan
that may be forgiven?
◦ Under the Act, payroll costs are calculated on a gross basis without regard to (i.e., not including
subtractions or additions based on) federal taxes imposed or withheld, such as the employee’s and
employer’s share of Federal Insurance Contributions Act (FICA) and income taxes required to be
withheld from employees. As a result, payroll costs are not reduced by taxes imposed on an employee
and required to be withheld by the employer, but payroll costs do not include the employer’s share of
payroll tax. For example, an employee who earned $4,000 per month in gross wages, from which $500
in federal taxes was withheld, would count as $4,000 in payroll costs. The employee would receive
$3,500, and $500 would be paid to the federal government. However, the employer-side federal payroll
taxes imposed on the $4,000 in wages are excluded from payroll costs under the statute.
Confidential ©2020 Holsinger P.C. All Rights Reserved.The SBA FAQ Says:
◦ BUT WAIT: THERE IS A FOOTNOTE!!!
◦ The definition of “payroll costs” in the CARES Act, 15 U.S.C. 636(a)(36)(A)(viii), excludes “taxes imposed or withheld under
chapters 21, 22, or 24 of the Internal Revenue Code of 1986 during the covered period,” defined as February 15, 2020, to June
30, 2020. As described above, the SBA interprets this statutory exclusion to mean that payroll costs are calculated on a gross
basis, without subtracting federal taxes that are imposed on the employee or withheld from employee wages. Unlike employer-
side payroll taxes, such employee-side taxes are ordinarily expressed as a reduction in employee take-home pay; their exclusion
from the definition of payroll costs means payroll costs should not be reduced based on taxes imposed on the employee or
withheld from employee wages. This interpretation is consistent with the text of the statute and advances the legislative
purpose of ensuring workers remain paid and employed. Further, because the reference period for determining a borrower’s
maximum loan amount will largely or entirely precede the period from February 15, 2020, to June 30, 2020, and the period
during which borrowers will be subject to the restrictions on allowable uses of the loans may extend beyond that period, for
purposes of the determination of allowable uses of loans and the amount of loan forgiveness, this statutory exclusion will apply
with respect to such taxes imposed or withheld at any time, not only during such period.
◦ DOES THIS SOLVE THE GROSS VS. NET PAY ISSUE???
◦ FURTHER CLARIFICATION TO BE PROVIDED…
Q20: The amount of forgiveness of a PPP loan depends on the borrower’s payroll costs over an eight-week period;
when does that eight-week period begin?
◦ The eight-week period begins on the date the lender makes the first disbursement of the PPP loan to the borrower. The
lender must make the first disbursement of the loan no later than ten calendar days from the date of loan approval.
Confidential ©2020 Holsinger P.C. All Rights Reserved.Summary:
Conservatively it is our understanding that loan forgiveness will be dependent on three metrics:
◦ Number of Employees: The number of employees on the PPP application will be compared to the
number of employees during he covered period.
◦ Any reduction can result in a proportional reduction in the ability to receive loan forgiveness.
◦ Proportion of PPP Proceed Spend: 75% of PPP Proceeds spent must be spent on “Payroll Costs”; 25%
can be spent on other eligible costs.
◦ Unclear if this is a “light switch” or proportion reduction of forgiveness.
◦ Average Monthly Payroll Cost (per application) vs. Average Monthly Payroll Cost (during covered
period).
◦ More than at 25% reduction at the employee level or in total can result in either proportional or total loan forgiveness.
Confidential ©2020 Holsinger P.C. All Rights Reserved.Deeper Dive (Forgiveness Metrics):
Qualifying Expenses Metric:
◦ The requirement that only “costs incurred and payments made” within the 8-week period will be forgiven may seem
innocuous, but it has the potential to create a host of problems.
◦ Leads to accrual vs. cash basis determination of expenses…
◦ Seems to insinuate one of two options:
◦ Combination of accrual and cash basis accounting: In this case both concepts are required for the expense to be eligible. This would create significant
prepayment issues with respect to eligible expenses considering the requirement that the spend be justified as both incurred during the covered
period and paid for during the covered period.
◦ Either or approach: The all-encompassing interpretation where either costs accrued and incurred plus costs paid during the covered period would
count. This would eliminate concern regarding prepayments of any expenses…
◦ More guidance on this is certainly necessary…
◦ Payroll Costs Determination:
◦ It is unclear if the “Payroll Costs” as a qualifying use of proceeds will include gross wages of employees or will be based on a net wage, plus employee
state and local tax withholding, plus employer share of state and local tax (SUTA).
◦ It appears that the SBA is leaning toward a Gross Wage determination consistent with the determination of the max loan value.
◦ Definitive guidance would certainly be appreciated…
◦ Interest Payments:
◦ It is unclear if payments for interest on preexisting debt (not mortgage indebtedness) will count as an eligible expense…
◦ It is unclear if this is an “all or nothing” or proportional provision?
Confidential ©2020 Holsinger P.C. All Rights Reserved.Deeper Dive (Forgiveness Metrics):
Number of Employees Metric:
◦ Here is how some are interpreting the guidance:
◦ The CARES Act provides that the amount of loan forgiveness is reduced by multiplying the amount eligible for
forgiveness by the quotient obtained by dividing:
◦ The average number of full-time equivalent employees per month employed by the eligible recipient during the covered period; by
◦ At the election of the borrower, either:
◦ The average number of full-time equivalent employees per month employed by the eligible recipient during the period beginning on
February 15, 2019 and ending on June 30, 2019; or
◦ The average number of full-time equivalent employees per month employed by the eligible recipient during the period beginning on January
1, 2020 and ending on February 29, 2020.
◦ What this means: Under this interpretation, a business must measure:
◦ Its average FTEs for each pay period during the 8-week covered period;
◦ Its average FTEs for the period 2/15/19 – 6/30/19;
◦ Its average FTEs for the period 1/1/20 – 2/29/20
◦ Its average FTEs for the period 2/15/20 – 4/27/2020
◦ Its number of FTEs on 2/15/20.
Confidential ©2020 Holsinger P.C. All Rights Reserved.Deeper Dive (Forgiveness Metrics):
Number of Employees Metric:
◦ First, the business must compare the ratio of the average FTEs during the 8 week covered period to the
average FTEs during the period 2/15/19 – 6/30/19 or the period 1/1/2020 – 2/29-2020.
◦ To the extent that the ratio is not 100% or greater, all is not lost; the company can then look to the
following exceptions:
◦ The average number of FTEs during the period 2/15/2020 to 4/27/2020 vs. the average number of FTEs on 2/15/2020;
◦ To the extent that that ratio is not 100% or greater, al is not lost; the company can ignore all reduction in number of employees if
by 6/30/2020, the number of FTEs as of 2/15/2020 is restored to 100%.
Confidential ©2020 Holsinger P.C. All Rights Reserved.Deeper Dive (Forgiveness Metrics):
Average Monthly Payroll Cost:
◦ It sounds like this will be measured on an EE by EE basis. Sounds like a lot of work…
◦ It is unclear if this can be overridden by meeting the number of employees metric.
◦ What if an employee quits or is terminated? Can they be replaced?
◦ It is unclear if this is an “all or nothing” or proportional provision?
Confidential ©2020 Holsinger P.C. All Rights Reserved.Self Employment Rules Clarified:
Generally, the PPP loan determination concepts and calculations are the same.
Sole Proprietors, Independent Contractors and Eligible Self-Employed Individuals are effectively
permitted to apply for relief through the PPP based on two factors rather than only “Payroll Costs” as
defined for business applicants. The two factors are:
◦ Monthly “Payroll Costs” as Defined in the Act;
◦ Plus, up to $100K of Self Employment earnings as reported on Schedule C of Form 1040 for the year 2019
Eligible Support of Loan Determination:
◦ Applicants must provide the 2019 Schedule C (even if not filed) as representation of the 2019 earnings of the
business.
◦ Further support that may be requested:
◦ 2019 IRS Form 1099-MISC detailing nonemployee compensation received, invoice, bank statement or book of record that establishes you are
self-employed.
◦ a 2020 invoice, bank statement or book of record to establish you were in operation on or around February 15, 2020
◦ If you have employees, Form 941 and state quarterly unemployment insurance tax reporting forms or equivalent payroll processor records
that best correspond to the covered period (with evidence of any retirement and health insurance contributions)
SBA will issue additional guidance for those individuals with self-employment income who were not in operation
in 2019 but who were in operation on February 15, 2020 and will file a Form 1040 Schedule C for 2020.
Confidential ©2020 Holsinger P.C. All Rights Reserved.Self Employment Rules Clarified:
The proceeds of the loans can be used for the following:
1. Owner compensation replacement, calculated based on 2019 net profit
2. Employee payroll costs
3. Mortgage Interest payments on any business mortgage obligation on real or person property (e.g. the interest
on your mortgage for the warehouse you purchased to store business equipment or the interest on an auto
loan for a vehicle you use to perform your business
◦ Business rent payments (e.g. again, warehouse or vehicle you lease for business)
◦ Business utility payments (e.g. utilities in warehouse used for business or gas for the vehicle you own/lease)
◦ Note that you must have claimed or be entitled to claim a deduction for such expenses on your 2019 Form 1040 Schedule C for them to be a permissible
use during the eight-week period following the first disbursement of the loan (the “covered period”).
◦ For example, if you did not claim or are not entitled to claim utilities expenses on your 2019 Form 1040 Schedule C, you cannot use the proceeds for
utilities during the covered period.
4. Interest payments on any other debt obligations that were incurred before Feb. 15, 2020 (note that you can
use the loan to pay interest but such amounts are NOT eligible for PPP loan forgiveness)
5. Refinancing an SBA EIDL loan made between 1/31/2020 and 4/3/2020
Confidential ©2020 Holsinger P.C. All Rights Reserved.Self Employment Rules Clarified:
Sole Proprietors, Independent Contractors and Eligible Self-Employed Individual applicants are also eligible for
loan forgiveness. The actual amount of loan forgiveness will depend, in part, on the total amount spent over the
covered period on:
1. Owner compensation replacement, calculated based on 2019 net profit but limited to eight weeks worth
(8/52) of 2019 profits… whereas loan amount is based on 2.5 months of net profit which provides a gap
2. Employee payroll costs as defined previously
3. Mortgage Interest payments on any business mortgage obligation on real or person property (e.g. the interest
on your mortgage for the warehouse you purchased to store business equipment or the interest on an auto
loan for a vehicle you use to perform your business
◦ Business rent payments (e.g. again, warehouse or vehicle you lease for business)
◦ Business utility payments (e.g. utilities in warehouse used for business or gas for the vehicle you own/lease)
◦ Note that you must be able to claim these expenses on your Schedule C for them to be a permissible use during the 8 week period following the first
disbursement of the loan
4. Interest payments on any other debt obligations that were incurred before Feb. 15, 2020 (note that you can
use the loan to pay interest but such amounts are NOT eligible for PPP loan forgiveness)
But wait… there is ambiguity in the Interim Final Rules whereas page 11 allows the above to be forgiven, page 12 of the same document
goes on to state that the forgiveness will be limited to a proportionate eight-week share of 2019 net profit, as reflected in the individual's
2019 Form 1040 Schedule C. We will assume that the writers’ of the Interim Final Rule meant what they said on pages 11 and 13 and
allow complete forgiveness as described above.
Confidential ©2020 Holsinger P.C. All Rights Reserved.Summary of Payroll Tax Credits
Employee Retention Credits (All Employers) :
◦ Up to $5,000 per employee (50% of up to $10,000 of Qualifying Wages paid between 3/12/20 –
01/01/21 if during a “Covered Period”)
◦ “Wages” include qualified health plan expenses
◦ Difference in Definition based on size of employer (100 Employees)
Emergency Paid Sick Leave Credit (Employer Eligibility Summary:
Emergency Paid
Employee Retention
EIDL Program PPP Loans Sick Leave
Payroll Credit
Payroll Credit
Employee Retention No credit allowed if PPP Loan
No Restrictions
Payroll Credit obtained.
Qualified Wages for the
Loan Forgiveness' qualifying
Emergency Paid Employee Retention Payroll
Payroll Costs exclude any wages
Sick Leave No Restrictions Credit excludes any wages that
that are utilized for Qualified Paid
Payroll Credit are utilized for Qualified Paid Sick
Sick Leave Credits
Leave Credits
Qualified Wages for the
Loan Forgiveness' qualifying Paid Sick Leave can be used in
Emergency Paid Employee Retention Payroll
Payroll Costs exclude any wages conjunction with Paid Family
Family Leave No Restrictions Credit excludes any wages that
that are utilized for Qualified Paid Leave. Practically it would be
Payroll Credit are utilized for Qualified Paid
Family Leave Credits used sequentially.
Family Leave Credits
Confidential ©2020 Holsinger P.C. All Rights Reserved.Employer Eligibility Summary:
Non-Profits
500 Employees
Any size organization can qualify
Employee Retention
Payroll Credit Only Wages Paid for Employees Only Wages Paid for Employees
All Wages Qualify up to Limits
Not Working Not Working
Emergency Paid
Sick Leave Qualifying Wages up to Limits Qualifying Wages up to Limits Not-eligible
Payroll Credit
Emergency Paid
Family Leave Qualifying Wages up to Limits Qualifying Wages up to Limits Not-eligible
Payroll Credit
Confidential ©2020 Holsinger P.C. All Rights Reserved.Employer Eligibility Summary:
For-Profits
500 Employees
Any size organization can qualify
Employee Retention
Payroll Credit
Only Wages Paid for Employees Only Wages Paid for Employees
All Wages Qualify up to Limits
Not Working Not Working
Emergency Paid
Sick Leave Qualifying Wages up to Limits Qualifying Wages up to Limits Not-eligible
Payroll Credit
Emergency Paid
Family Leave Qualifying Wages up to Limits Qualifying Wages up to Limits Not-eligible
Payroll Credit
Confidential ©2020 Holsinger P.C. All Rights Reserved.Summary of Payroll Tax Credits Affects
◦ All are fully refundable – they can offset both employer and employee federal payroll
taxes
◦ Offsets all payroll related taxes – withheld federal income tax as well as the employee
AND employer share of Social Security & Medicare taxes.
Credit Calculation Example Cash Flow Example
Sick or Family Leave Employee Retention (federal tax only)
Wages 8,000 8,000 Sick or Family Leave Employee Retention
Health Care Expenses 1,000 1,000 Cash Balance 9,000 9,000
Qualified Wages 9,000 9,000
Total Credit 9,000 4,500 Net Wages (6,588) (6,588)
Healthcare Expenses (1,000) (1,000)
Withholding (800) (800) Refunded Tax Credit 6,976 2,476
SS & Medicare (1,224) (1,224)
Total Payroll Taxes (2,024) (2,024) Ending Cash Balance 8,388 3,888
Refundable Credit 6,976 2,476
Confidential ©2020 Holsinger P.C. All Rights Reserved.Main Street Lending Program:
On April 9, 2020, The Federal Reserve has announced that it is establishing
a $600 billion Main Street Lending Program to support lending to small
and medium-sized businesses that were in good financial standing before
the onset of the COVID-19 pandemic.
The program will operate through two facilities:
1. The Main Street New Loan Facility (MSNLF) for loans originated by
lenders on or after April 8, 2020
2. The Main Street Expanded Loan Facility (MSELF) for loans originated
by lenders before April 8, 2020.
The program is not yet operational or accepting application as the
Department of Treasury was seeking public comments until yesterday,
April 16, 2020.
Firms that have taken advantage of the PPP may also take out Main Street
loans.
Confidential ©2020 Holsinger P.C. All Rights Reserved.Main Street Loan:
Key Points
Eligible borrowers are business with up to 10,000 employees or up to $2.5 billion in 2019 annual revenues
Eligible borrower must be a business that is created or organized in the US or under the laws of the US with significant operations in and a majority of its employees based in
the US
No minimum company size requirement for eligibility
Company must have at least $250,000 in earnings before interest, taxes, depreciation and amortization (EBITDA) and no debt
Companies with debt have higher EBITDA requirements
4 year maturity; amortization of principal and interest deferred for one year
Interest rates are variable and right now range from 2.5 percent to 4 percent
Minimum loan amount is $1 million
Maximum
MSNLF: Less of $25 million or an amounts that does not exceed 4 x 2019 EBITDA
MSELF: Lesser or $150 million; 30% of borrowers existing outstanding and committed but undrawn bank debt or an amount that, when added to the existing debt does
not exceed six times 2019 EBITDA
Prepayment without Penalty
MSNLF will purchase unsecured term loans and charge a 100-basis-point facility fee; MSELF, which facilitates increases to loans that predate the programs, will purchase
secured loans, will not charge a facility fee and allows for potentially larger loan sizes
Confidential ©2020 Holsinger P.C. All Rights Reserved.Summary of Key Terms and Conditions
as provided by BakerHostetler Article dated April 13, 2020 titled “Fed Announces Framework of the Main Street Lending Program”
https://www.jdsupra.com/legalnews/fed-announces-framework-of-the-main-76943/
Confidential ©2020 Holsinger P.C. All Rights Reserved.Summary of Key Terms and Conditions
(continued):
Confidential ©2020 Holsinger P.C. All Rights Reserved.Thank you for attending!
Contact Information:
Bill Collier: bill.collier@thinkholsinger.com
Andy Bianco: andy.bianco@thinkholsinger.com
William Stunkel: William.Stunkel@thinkholsinger.com
Jessica Moslander: Jessica.Moslander@thinkholsinger.com
www.thinkholsinger.com
Please feel free to reach out to us if you have any additional questions!
Confidential ©2020 Holsinger P.C. All Rights Reserved.WILLIAM R. COLLIER, CPA, MST
Education and Certifications:
B.S. in Accounting, Grove City College
Masters in Taxation, Robert Morris University
Certified Public Accountant, Pennsylvania
Experience:
In his role as Vice President and Tax Partner-In-Charge, Bill Collier manages the firm’s tax
operations, family office group and M&A team. He applies his highly skilled expertise to develop
tax saving ideas for our clients business challenges. He develops internal standards governing the
delivery of tax services to clients and maintains a close pulse on the legislative and regulatory
changes impacting our client’s tax positions, both domestically and internationally.
University
Confidential ©2020 Holsinger P.C. All Rights Reserved.ANDY BIANCO, CPA/MT
Education and Certifications:
B.S. in Accounting, St. Vincent College with a minor in Finance
Masters of Taxation, Villanova University School of Law
Certified Public Accountant, Pennsylvania
Experience:
As a Shareholder at Holsinger, has over a decade of experience in the areas of tax, accounting,
auditing, forensic accounting, mergers and acquisitions and general business consulting services.
Andy has served both domestic and international clients in a broad range of industries during his
career in the accounting profession. He consistently proves value through quality service,
attention to detail and unique perspective.
Confidential ©2020 Holsinger P.C. All Rights Reserved.WILLIAM L. STUNKEL, CPA
Education and Certifications:
B.S. in Accounting (with Honors), Grove City College
Certified Public Accountant, Pennsylvania
Experience
While being the Director of Holsinger’s Business Solutions (“HBS”) group, Wil has over fourteen years
of experience in areas of accounting, tax planning, payroll and financial literacy. Wil has extensive
experience with private companies in a broad range of industries including manufacturing,
construction, restaurants, professional services, non-profit organizations, home healthcare, and
others. He has worked extensively with clients in structuring compensation for themselves as well as
for clients’ employees to ensure the most efficient tax treatment. He specializes in working with small
business owners to give them the attention and analysis they want while helping them increase their
income.
Confidential ©2020 Holsinger P.C. All Rights Reserved.JESSICA MOSLANDER, CPA
Education and Certifications:
B.A. in both Accounting and Business Administration (Magna Cum Laude), Thiel College
Certified Public Accountant, Pennsylvania
Experience:
Jessica, a Tax Manager at Holsinger is a CPA with over 18 years of experience in tax preparation,
tax planning, research and consulting. Her main focus has been multistate and consolidated
business returns which includes both domestic and foreign entities. Jessica also has extensive
experience in tax research, resolving client issues with state and federal authorities and
developing tax planning strategies for multistate and multinational corporations along with
owners of pass through entities.
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